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People v. Scott

Supreme Court of California
927 P.2d 288 (1996)


Facts

The romantic relationship between Calvin Hughes and Elaine Scott soured, and their interactions became increasingly hostile, resulting in a physical altercation one evening. Scott’s adult sons, Damien Scott and Derrick Brown (defendants), came to their mother’s aid and forced Hughes from the shared apartment. A few days later, Hughes and a friend drove to a neighborhood park. The defendants followed Hughes, drove into the park, and sprayed the area with bullets from an automatic weapon, intending to kill Hughes. Instead, a bystander was killed, and several others were injured by the gunfire. The defendants were indicted on several charges, including the murder of the bystander and attempted murder of Hughes and his friend. At the close of a second trial, the trial court instructed the jury on the doctrine of transferred intent as applied to murder. The defendants were convicted of second-degree murder and two counts of attempted murder. The defendants appealed. The court of appeals affirmed the convictions, rejecting the defendants’ claim that transferred intent applies only if the prosecution charges a defendant with first-degree murder of the unintended victim and cannot apply if a defendant is charged with the attempted murder of the intended victim. The Supreme Court of California granted certiorari to review.

Rule of Law

Issue

Holding and Reasoning (Brown, J.)

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